Martin v. State

Bernes, Judge.

Following a bench trial, Shawn Lee Martin was convicted of sexual battery. On appeal, Martin contends that the state failed to prove beyond a reasonable doubt that venue was in Habersham County. We disagree and affirm.

Generally, a criminal action must be tried in the county in which the crime was committed (Ga. Const. 1983, Art. VI, Sec. II, Par. VI; OCGA § 17-2-2 (a)), and the [s]tate may establish venue by whatever means of proof are available to it, including direct and circumstantial evidence. As an appellate court, we view the evidence in a light most favorable to support…